Does the primary purpose exception apply to companies that distribute financial products (such as prepaid cards) that provide access to funds at one or more insured depository institutions?

Compliance > Deposits > Brokered Deposits
Q:  Does the primary purpose exception apply to companies that distribute financial products (such as prepaid cards) that provide access to funds at one or more insured depository institutions?
 
A:    Whether such companies qualify as deposit brokers depends upon the circumstances. As illustrated by the FAQs below, the primary purpose exception generally does not apply to such companies, and consequently, they are classified as deposit brokers, and the deposits would be brokered.
 

This can be found in FDIC’s FAQs, which can be found at https://www.fdic.gov/news/news/financial/2015/fil15002a.pdf

Add Feedback